Reports of the Tax Court of the United States, Volume 118U.S. Government Printing Office, 2002 |
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affd agreement alternative minimum tax amount Appeals officer apply assessment assets Beech Trucking benefit Blonien Burndy-Japan Burndy-US Caracci claim Clinpath stock Commissioner computing corporation deduction distribution documents EAPR election employees Estate fair market value Farm Federal income tax filed Finley Kumble Framatome Furukawa and Sumitomo Galena airport gross income home health Income Tax Regs income tax return interest expense interest income Internal Revenue Internal Revenue Code issue jurisdiction Leasing legislative history manufactured ment minimum tax notice of deficiency paid parties partner partnership percent peti petition petitioner's Petitioners contend Puerto Rico purposes pursuant regulations reimbursement Rept respect respondent's Revenue Procedures Rule shareholders shares sioner Sta-Home tax-exempt entities statute statutory stipulated summary judgment Sun Shipping supra T.C. Memo Tate & Lyle Tax Court tax liability taxable income taxpayer tion trade or business transfer Treeco United video games WHTC
Popular passages
Page 179 - provides: If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise * * * Thus,
Page 341 - Income Tax Regs. Fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts. Sec. 1.170Al(c)(2), Income Tax Regs.
Page 100 - "the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.'" United States v. Cartwright, 411 US
Page 97 - the price at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts". United States v. Cartwright, 411 US 546, 551
Page 316 - the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
Page 273 - When an act of Congress is appropriately challenged in the courts as not conforming to the constitutional mandate the judicial branch of the Government has only one duty,—to lay the article of the Constitution which is invoked beside the statute which is challenged and to decide
Page 3 - SEC. 38. GENERAL BUSINESS CREDIT. (a) ALLOWANCE OF CREDIT.—There shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the sum of— (1) the business credit carryforwards carried to such taxable year, (2) the amount of the current year business credit, plus (3) the business credit
Page 309 - treaty and statute relate to the same subject, the courts will always endeavor to construe them so as to give effect to both, if that can be done without violating the language of either; but if the two are inconsistent, the one last in date will control the other, * * * [Whitney v. Robertson,
Page 85 - No gain or loss shall be recognized to a corporation if such corporation is a party to a reorganization and exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Page 169 - In making the foregoing determinations, the court shall review the whole record or those parts of it cited by a party, and due account shall be taken of the rule of prejudicial error. [Emphasis added.]